Section 1274.—Determi- nation of Issue Price in the Case of Certain Debt Instru- ments…

(Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2005.

Rev. Rul. 2005–66

This revenue ruling provides various prescribed rates for federal income tax purposes for October 2005 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(2) for buildings placed in service during the current month. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.

2005–41 I.R.B. 686 October 11, 2005

REV. RUL. 2005–66 TABLE 1

Applicable Federal Rates (AFR) for October 2005

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term

AFR 3.89% 3.85% 3.83% 3.82% 110% AFR 4.28% 4.24% 4.22% 4.20% 120% AFR 4.67% 4.62% 4.59% 4.58% 130% AFR 5.07% 5.01% 4.98% 4.96%

Mid-term

AFR 4.08% 4.04% 4.02% 4.01% 110% AFR 4.49% 4.44% 4.42% 4.40% 120% AFR 4.91% 4.85% 4.82% 4.80% 130% AFR 5.32% 5.25% 5.22% 5.19% 150% AFR 6.15% 6.06% 6.01% 5.98% 175% AFR 7.19% 7.07% 7.01% 6.97%

Long-term

AFR 4.40% 4.35% 4.33% 4.31% 110% AFR 4.85% 4.79% 4.76% 4.74% 120% AFR 5.29% 5.22% 5.19% 5.16% 130% AFR 5.74% 5.66% 5.62% 5.59%

REV. RUL. 2005–66 TABLE 2

Adjusted AFR for October 2005

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted 2.83% 2.81% 2.80% 2.79% AFR

Mid-term adjusted AFR 3.27% 3.24% 3.23% 3.22%

Long-term adjusted 4.14% 4.10% 4.08% 4.07% AFR

REV. RUL. 2005–66 TABLE 3

Rates Under Section 382 for October 2005

Adjusted federal long-term rate for the current month 4.14%

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 4.24%

REV. RUL. 2005–66 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for October 2005 Appropriate percentage for the 70% present value low-income housing credit 7.98%

Appropriate percentage for the 30% present value low-income housing credit 3.42%

October 11, 2005 687 2005–41 I.R.B.

REV. RUL. 2005–66 TABLE 5

Rate Under Section 7520 for October 2005

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 5.0%

timated income tax regulations will clarify the estimated income tax regulations under section 6654 of the Code. Removal of §§1.6015(a)–1 through 1.6015(j)–1 also alleviates any confusion under the current section 6015 regulations, which address relief from joint and several liability for an individual who has made a joint return. Adding §§1.6654–5 and 1.6654–6 will provide additional instructions for determining estimated tax payments and additional guidance for nonresident alien individuals required to make estimated tax payments.

Special Analyses

Because these regulations are interpretative and generally re-codify, under an existing statute, existing rules promulgated under a prior statute, notice and public comment procedures are not required pursuant to 5 U.S.C. 553(b)(A) and (B), and a delayed effective date is not required pursuant to 5 U.S.C. 553(d)(2) and (3). Because no notice of proposed rulemaking is required, the provisions of the Regulatory Flexibility Act, 5 U.S.C. 601 ( et seq .) do not apply. Further, because this Treasury decision is not a significant regulatory action for purposes of Executive Order 12866, a regulatory assessment is not required. Pursuant to section 7805(f) of the Code, these regulations were submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business.

Drafting Information

The principal author of these regulations is Tatiana Belenkaya, Office of Associate Chief Counsel (Procedure and Administration), Administrative Provisions and Judicial Practice Division.

- - - -

Adoption of Amendments to the Regulations

Accordingly, 26 CFR part 1 is amended as follows: